February 15, 2008
The Honorable James B. Gulliford
Assistant Administrator for Prevention, Pesticides and Toxic Substances
Environmental Protection Agency
1201 Pennsylvania Avenue
Washington, D.C. 20460
Dear Assistant Administrator Gulliford:
During the recently concluded midyear conference of the National Association of State Departments of Agriculture (NASDA), we adopted a resolution regarding an issue that we know is now before the Office of Pesticides.
NASDA members are especially concerned about the continued availability of effective agricultural products that are critical to producers and the farm economy. As you know, the state departments of agriculture have long been the lead state agencies for implementing federal pesticide laws, and we support efforts to ensure that chemical/pesticide use does not cause unreasonable adverse affects to human health and the environment.
The Environmental Protection Agency’s (EPA) proposal to cancel the crop protection chemical carbofuran is a matter of concern, particularly to our Midwestern corn growing states. The use of carbofuran is also important to specialty crop producers, especially when there are no alternative or cost-effective products. For these reasons, there is a need to retain the use of carbofuran for essential uses until an effective alternative product is available in the marketplace. It is our understanding that some of these same issues were raised during a recently concluded Science Advisory Panel (SAP) discussion on the subject.
Please let me know if you have any questions regarding this issue which was presented by Illinois Agriculture Director Chuck Hartke and Iowa Secretary of Agriculture Bill Northey.
We appreciate your consideration in this matter and stand ready to work with EPA on this important matter.
Sincerely,
Roger Johnson
NASDA President
Commissioner, North Dakota Department of Agriculture
Cc: Jon Scholl, Agricultural Counselor to the EPA Administrator
Chuck Conner, Deputy Secretary, USDA